ATTN: ALL FULL MEMBERS
Dear Members,
Reference to the EU Commission consultation on the implementing acts of the EU ETS and thanks to additional feedback received by one member with regards to the administering authority it has been highlighted that the way the regulation is currently drafted, may result for the ship manager to deal with a number of different administrations (AA) for submitting EUAs, rather than dealing with the one Administration of the branch offices location.
More specifically the below are highlighted:
- While the Draft Implementing Regulation (attached for reference) provides the process to be followed for the transfer of responsibility from Shipowner to Ship Manager under the EU ETS, attention is drawn to article I.3.(b) suggesting that the document that needs to be provided to the administering authority should include: “the country of registration of the organization or person mandated by the shipowner, as recorded under the IMO Unique Company and Registered Owner Identification Number Scheme”.
- It may be possible the IMO Unique Company Identification Number for management companies located in a Country (X) will not indicate Country (X) as the country of register but other non-EU countries (e.g. Liberia, Panama, Marshal Islands, etc.) and in this case for companies registered outside EU, the administering authority will be defined based on the greatest number of port calls in Member States performed by the fleet of the shipping company in the preceding 4 monitoring years and will be indicated in a list to be published by EC (Adm. Authority may change every time the list is updated).
- In order to avoid the result for the ship manager to deal with a number of different administrations (AA) for submitting EUAs, rather than dealing with the one Administration of the branch offices location the below was proposed:
[Q]
Thank you for the well-structured implementing act. Pls consider to revise article I.3.(b) (the country of registration of the organisation or person mandated by the shipowner, as recorded under the IMO Unique Company and Registered Owner Identification Number Scheme) to give the option for the shipowner or the delegated ship manager to surrender the EUAs to the EU members state their branch office is located.
[U/Q]
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Further to the initial feedback received and included in our previous circular [ref: 0919-F> EU ETS delegated acts: Feedback received | entity responsible to surrender the EU ETS allowances and the administering authority], the above information will be shared with our Associate member ECSA in order that all comments are shared with the EU Commission.
Kind regards
Emmanuel Vergetis
Regional Representative
Athens- Greece
